Marvin F. Poer and Company v. The Counties of Alameda

Appellants brought an action at law against all California counties, their auditors and tax collectors, and others for a refund of property taxes paid for the 1978-1979 tax year, or for damages in the amount of taxes paid. The ease presented the issue of the constitutionality of Article XIIIA of the California Constitution (“Proposition 13”) as applied to the taxpayers. Appellants sought a federal forum for their constitutional claims since federal courts, they argued, are free from political and precedential pressures of the state court system.

Appellees brought a motion to dismiss, based on the Tax Injunction Act, 28 U.S.C. § 1341 , and other grounds. The District Court dismissed the suit on the basis that the Tax Injunction Act barred federal court consideration of Appellants’ complaint. For the reasons stated below, we affirm the District Court’s decision.

In 1937, Congress enacted the Tax Injunction Act, 28 U.S.C. § 1341 (hereafter “the Act”), which states:

By its plain language, the Act deprives federal district courts of subject matter jurisdiction over actions for injunctive relief from state taxation schemes. E.g., Moe v. Confederated Salish and Kootenai Tribes, 425…